COVER 12 filename12.htm

SEC letter

ROPES & GRAY LLP   PRUDENTIAL TOWER   800 BOYLSTON STREET   BOSTON, MA 02199-3600   WWW.ROPESGRAY.COM

May 12, 2025 Ryan Murphy T +1 415 315 1285 Ryan.Murphy@ropesgray.com

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-0505

Re: PIMCO New York Municipal Income Fund II

Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14

(File Nos. 333-286389)

Ladies and Gentlemen:

On behalf of PIMCO New York Municipal Income Fund II, a Massachusetts business trust (“PNI”), we are today filing via EDGAR Pre-Effective Amendment No. 1 (the “Amendment”) to a registration statement on Form N-14 (the “Registration Statement”). The Registration Statement relates to the proposed reorganizations of PIMCO New York Municipal Income Fund and PIMCO New York Municipal Income Fund III with and into PNI, as described in the Registration Statement.

This Amendment to the Registration Statement is being filed for the purpose of responding to comments from the staff of the Securities and Exchange Commission and to make certain other changes.

Registration fees have been paid in connection with this filing. Please direct any questions or comments regarding this filing to me at (415) 315-1285 or to Chelsea M. Childs at (415) 315-6374. Thank you for your attention in this matter.

Very truly yours,

/s/ Ryan Murphy    

Ryan Murphy

cc: Ryan G. Leshaw, Esq.

Timothy Bekkers, Esq.

Jaime Dinan, Esq.

David C. Sullivan, Esq.

Chelsea M. Childs, Esq.